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For the 5 night VFR hours and 10 T/O at class B/C/D required in 14 CFR 61.129(a)(4)(ii), can you mix/match solo and dual instruction (as PIC) time for these hours and landings? In other words, are they combinable? I may reach all 5 solo but definitely have more than 5 night dual (as PIC).

Also, does being under the hood dual with CFI count? I would expect not since you're not flying "the traffic pattern" (i.e. right base, straight in, etc.) but just wanted to get consensus.

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  • $\begingroup$ Partially related $\endgroup$
    – Pondlife
    Commented Feb 26, 2021 at 20:03
  • $\begingroup$ Under 61.129 (a)(4) you cannot mix/match having a cfi on board with being solo. All of the requirements of 61.129 (a)(4) have to be either solo or with an authorized instructor on board. (Combining some solo hours with instructor on board hours is not allowed). $\endgroup$
    – user22445
    Commented Sep 18, 2021 at 19:17
  • $\begingroup$ None of the instructor on board (vs solo) time (10 hours) under FAR 61.129 (a)(4) would be "dual" (instruction given/ received). $\endgroup$
    – user22445
    Commented Sep 18, 2021 at 20:10

2 Answers 2

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No being under the hood does not count as "night flying" see this question for the FAA's definition of night flight.

You dont need to be alone in the aircraft for these TO/LD's while the FAA definition of "solo flight" which this question covers could apply it does state that an instructor can be present

(4) Ten hours of solo flight time in a single engine airplane or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board (either of which may be credited towards the flight time requirement under paragraph (a)(2) of this section), on the areas of operation listed under § 61.127(b)(1) that include -

(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower.

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  • $\begingroup$ Perhaps the OP is thinking about the wording that follows the part you quoted: "or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board". $\endgroup$
    – Pondlife
    Commented Feb 26, 2021 at 20:00
  • $\begingroup$ @Pondlife thanks for the note, i have updated accordingly $\endgroup$
    – Dave
    Commented Feb 26, 2021 at 20:50
  • $\begingroup$ Thanks. Yes, so I guess just wondering if the term 'or' implies a mix-n-match accumulation of hours, or do the hours need to be done mutually exclusive? At least 10 hours solo or at least 10 hours dual instruction as PIC but can't add up both to 10? $\endgroup$
    – saigafreak
    Commented Mar 2, 2021 at 20:59
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Long story short, you can have an instructor on board if you want but you can't log the time as training. And you can be under the hood if you want, as long as you're under the hood at night, in VFR conditions, and you're not logging it as training time.


Here's the relevant wording from 61.129:

Ten hours of solo flight time in a single engine airplane or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board

And:

5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower

First, what about dual? "Dual" isn't an official FAA term but "training received" is and it means that an instructor endorsed your logbook to show that they provided training. So, does 61.129 allow you to use that training time? Well, by definition (61.51(d)) "solo" means that you're alone in the aircraft, so clearly "solo" and "training received" can't happen at the same time.

That leaves "performing the duties of pilot in command in a single engine airplane with an authorized instructor on board". According to the Kuhn (2014) legal interpretation, you can have an instructor on board but you can't log it as training received:

Because this flight time is a substitute for solo flight time, the pilot is not receiving instruction and therefore cannot log this time as dual instruction received. The pilot can log the time to meet the requirements of § 61.129(a)(4) and log total flight time

Whether you want to pay a CFI to just sit there without you being able to log training time is up to you. The CFI can still log PIC time, by the way, according to the same interpretation.

Summing up the dual part, you cannot use training time as solo time. To meet the requirements in 61.129 you have two options: be alone in the aircraft, or have an instructor on board but not log any training time.

Second, what about hood time? "Night VFR conditions" describes the flight conditions but doesn't say anything about what happens inside the aircraft. I don't see anything that says you can't be under the hood with a safety pilot as long as you're also flying in night VFR conditions. In other words, being under the hood during daytime doesn't count: the requirement is to be in night VFR conditions.

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